18th June 2026

Further Objection and Request for Disclosure of Biodiversity Net Gain Evidence – DC/097786

Dear Planning Officer,

Further to my previous representation regarding application DC/097786 (Land at Padden Brook, Romiley), I wish to request disclosure and clarification of the ecological evidence relied upon by the applicant and the Council in assessing compliance with Biodiversity Net Gain requirements.

Given the apparent clearance of vegetation prior to determination of the application, there is a clear public interest in understanding how the pre-development biodiversity baseline has been established and whether the statutory biodiversity requirements have been correctly applied.

Accordingly, I would be grateful if the Council could confirm whether the following documents have been submitted and are available for public inspection:

• The completed Statutory Biodiversity Metric calculation spreadsheet (including all habitat unit calculations).

• The Biodiversity Gain Plan or equivalent biodiversity assessment documents.

• The Preliminary Ecological Appraisal and any subsequent ecological surveys.

• Habitat condition assessments used to derive biodiversity unit values.

• Any historical aerial imagery, site photographs, habitat maps, ecological records, or other evidence relied upon to reconstruct the site’s pre-clearance condition.

• Details of any proposed off-site biodiversity unit purchases.

• Details of any proposed statutory biodiversity credit purchases.

• Any review comments provided by the Council’s ecologist or ecological adviser.

For the avoidance of doubt, I also request that any Biodiversity Metric spreadsheets be made available in their original editable format, where possible, rather than solely as PDF extracts, so that the habitat classifications, condition assessments, multipliers, assumptions and unit calculations can be properly scrutinised.

I would also request clarification of the following matters:

  1. What habitat types were identified as existing immediately prior to vegetation clearance?
  2. What habitat distinctiveness and condition scores have been assigned within the biodiversity metric?
  3. Has any account been taken of hedgerows, trees, scrub habitat, grassland habitat, riparian habitat, and any other habitats associated with the site’s proximity to Padden Brook?
  4. What was the total biodiversity unit value of the site before development?
  5. What is the total biodiversity unit value proposed after development?
  6. What percentage Biodiversity Net Gain is predicted to be achieved?
  7. If off-site compensation is proposed, where will that compensation be located and how will it be secured for the required 30-year period?
  8. If statutory biodiversity credits are proposed, how many credits are required?
  9. Please confirm the number of biodiversity habitat units and hedgerow units that would have been attributed to the site had the baseline assessment been undertaken immediately prior to vegetation clearance. If alternative assumptions have been applied, please explain the basis for those assumptions and provide the evidence relied upon.
  10. Please confirm whether the Council has independently verified the pre-clearance baseline habitat assessment and whether any discrepancies have been identified between the site’s condition before clearance and the habitat classifications used within the submitted Biodiversity Metric.
  11. Has the Council’s ecological adviser accepted the applicant’s proposed baseline without amendment, or have revisions been required following review?
  12. If vegetation clearance occurred before ecological surveys were undertaken, please explain how the Council has ensured that the resulting biodiversity obligations have not been reduced as a consequence of those works.

In addition, I ask the Council to confirm whether it is satisfied that the ecological baseline has been established in accordance with Schedule 7A of the Town and Country Planning Act 1990, the Biodiversity Gain Requirements, and the relevant statutory guidance governing Biodiversity Net Gain assessments.

The current appearance of the site cannot, in itself, be considered reliable evidence of its biodiversity value before clearance. It is therefore essential that the baseline used for decision-making reflects the site’s actual condition immediately prior to those works and that any lost habitats are properly accounted for within the biodiversity metric calculations.

Given the irreversible nature of habitat loss and the importance of ensuring public confidence in the planning process, I respectfully request that no planning decision is issued until all biodiversity calculations, supporting evidence, ecological review comments and biodiversity offset proposals have been made available for public examination.

Should the Council conclude that the submitted information is insufficient to establish a robust pre-clearance ecological baseline, I respectfully request that further ecological evidence be obtained before the application is determined.

I would be grateful if this correspondence could be recorded as a formal objection and representation on the planning application file and that receipt of this submission is confirmed.

Yours faithfully,